APPLICATION FOR JUDGMENT DEBTOR EXAMINATION OF DEFENDANT/JUDGMENT DEBTOR CRAIG EHRNREITER, an individual

CAM FERENBACH, Magistrate Judge.

Plaintiffs BOARD OF TRUSTEES OF THE CONSTRUCTION INDUSTRY AND LABORERS HEALTH AND WELFARE TRUST; BOARD OF TRUSTEES OF THE CONSTRUCTION INDUSTRY AND LABORERS JOINT PENSION TRUST; BOARD OF TRUSTEES OF THE CONSTRUCTION INDUSTRY AND LABORERS VACATION TRUST; AND THE BOARD OF TRUSTEES OF THE SOUTHERN NEVADA LABORERS LOCAL 872 TRAINING TRUST, (hereinafter "Plaintiffs"), by and through its attorneys of record, Seth T. Floyd, Esq. of THE URBAN LAW FIRM, and pursuant to Rule 69 of the Federal Rules of Civil Procedure, hereby moves this Court for an Order directing the appearance of Defendant/Judgment Debtor Craig Ehrnreiter, an individual (hereinafter "Mr. Ehrnreiter"), and an Order directing the production of certain documents subject to his ownership and control.

This application is supported by the Declaration of Seth T. Floyd and the proposed Order filed herewith.

MEMORANDUM OF POINTS AND AUTHORITIES

Rule 69 of the Federal Rules of Civil Procedure allows a Judgment Creditor to enforce a judgment through supplementary proceedings, including discovery from the Judgment Debtors.

Judgment was entered on September 7, 2016, against Safety Sealed Water Systems LLC, Craig Ehrnreiter, individually, Lora Lee Ehrnreiter, individually and Scott Hefty, individually, in the amount of $186,452.85. The Clerk of the Court entered the Default Judgment on September 8, 2016.

Said judgment has not been vacated or reversed. The current balance due on the judgment is $186,452.85, exclusive of interest, and it remains owing and unpaid. There is no stay of execution and execution may properly be issued.

A judgment debtor examination of Mr. Ehrnreiter is necessary to enable Judgment Creditor to discover the assets, real and personal property, current employment, etc., and any facts relating thereto, which may assist Judgment Debtor in obtaining satisfaction of the Judgment.

WHEREFORE, pursuant to FRCP 69, Judgment Creditor respectfully requests that this Court issue an Order scheduling a judgment debtor examination of Judgment Debtor Craig Ehrnreiter.

DECLARATION OF SETH T. FLOYD IN SUPPORT OF APPLICATION FOR JUDGMENT DEBTOR EXAMINATION OF DEFENDANT/JUDGMENT DEBTOR CRAIG EHRNREITER, an individual

I, SETH T. FLOYD, declare:

1. I am a member of the Bar of this Court and attorney of record for the Judgment Creditors in the above-entitled action.

2. Judgment was entered on September 7, 2016, in the amount of One Hundred Eighty Six Thousand Four Hundred Fifty Two Dollars and Eighty Five Cents ($186,452.85), in favor of Plaintiffs and against Defendants Safety Sealed Water Systems LLC, Craig Ehrnreiter, individually, Lora Lee Ehrnreiter, individually and Scott Hefty, individually.

3. Said judgment has not been vacated or reversed. The current balance due on the judgment is $186,452.85, exclusive of interest, remains owing and unpaid. There is no stay of execution and execution may properly be issued.

4. Craig Ehrnreiter ("Mr. Ehrnreiter") is an individual believed to reside in Las Vegas, Nevada.

5. An Order scheduling an examination of Mr. Ehrnreiter and requiring production of documents by Mr. Ehrnreiter is necessary to pursue collection of the judgment. No prior examination has been conducted.

6. I estimate the time for the examination in this matter will be approximately three hours. The subject of this examination will be the location and identification of all assets of Mr. Ehrnreiter, and all debts and obligations owed to Mr. Ehrnreiter. In addition to the appearance of Mr. Ehrnreiter, the current financial statements and records and recent past financial statements and records of Mr. Ehrnreiter are necessary for a complete examination to be conducted.

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct, and that this declaration was executed on September 23, 2016, in Las Vegas, Nevada.

(Proposed)

ORDER FOR JUDGMENT DEBTOR EXAMINATION OF DEFENDANT CRAIG EHRNREITER, an individual

Having considered Plaintiffs' Application for Judgment Debtor Examination of Defendant/Judgment Debtor Craig Ehrnreiter, an individual and the Declaration of Seth T. Floyd and good cause appearing.

IT IS HEREBY ORDERED that Defendant/Judgment Debtor Craig Ehrnreiter, appear in Courtroom 3D at the United States District Courthouse for the District of Nevada, located at 333 Las Vegas Blvd. South, Las Vegas, Nevada 89101, on the 28th day of October, 2016, at 10:00 a.m., to be sworn in for a Judgment Debtor Examination.

IT IS FURTHER ORDERED that Defendant/Judgment Debtor Craig Ehrnreiter, appear at The Urban Law Firm, located at 4270 South Decatur Blvd., Suite A-9, Las Vegas, Nevada 89103 on the 28th day of October, 2016, at 11:00 a.m., and answer concerning property subject to the ownership and control of Craig Ehrnreiter (hereinafter referred to as "Mr. Ehrnreiter").

IT IS FURTHER ORDERED that Mr. Ehrnreiter brings with him the following documents under his control or under the control of its agents, attorneys or accountants:

a. All financial statements prepared by or on behalf of Mr. Ehrnreiter from January 1, 2014, to the present.

b. All original monthly bank statements of Mr. Ehrnreiter from January 1, 2014, to the present.

c. All original savings account pass books, certificates of deposit, and trust certificates in the name of Mr. Ehrnreiter January 1, 2014, to the present.

d. All canceled checks drawn on any account established in the name of Mr. Ehrnreiter from January 1, 2014, to the present.

e. All original negotiable instruments and negotiable securities in the name of Mr. Ehrnreiter from January 1, 2014, to the present.

f. All evidence or other memoranda of any ownership interest of Mr. Ehrnreiter in any corporation, partnership, unincorporated association or any business organized or conducted for the production of income from January 1, 2014, to the present.

g. All evidence or other memoranda of any income received by Mr. Ehrnreiter January 1, 2014, to the present, to include but not limited to tax returns, insurance proceeds, or repayment of loans.

h. All evidence or other memoranda of any employer, or place of work or employment of Mr. Ehrnreiter from January 1, 2014, to the present, including but not limited to contracts, invoices, billings, vouchers or payments.

i. All evidence of any ownership interest of Mr. Ehrnreiter to include but not limited to, bills of sale, pink slips or any other record or title, in any motor vehicle, airplane, boat, equipment or machinery, from January 1, 2014, to the present.

j. All evidence of any debts or repayments owed by Mr. Ehrnreiter, to include but not limited to, those arising from loans or judgments from January 1, 2014, to the present.

k. Any and all evidence or other memoranda indicating that Mr. Ehrnreiter was either a plaintiff or a defendant in any lawsuit from January 1, 2014, to the present.

1. Any and all evidence or memoranda indicating that Mr. Ehrnreiter received any judgment, award, bequest or devise in any lawsuit or other court action from January 1, 2014, to the present.

m. Any and all evidence or memoranda indicating any ownership interest of Mr. Ehrnreiter in any patent, invention, trade name, or copyright.

n. Any and all evidence or memoranda indicating an ownership interest of Mr. Ehrnreiter in any real property or developments on real property.

o. Any and all evidence of the sale(s) of any real or personal property of Mr. Ehrnreiter from January 1, 2014, to the present.

p. Any and all loan applications filled out by Mr. Ehrnreiter since January 1, 2014.

q. Copies of all documents evidencing the sale or transfer of any assets of Mr. Ehrnreiter from January 1, 2014, to the present.

r. Any and all documents evidencing any federal or State tax liability of Mr. Ehrnreiter.

s. Original cash disbursement journals and/or check registers maintained in connection with any business of Mr. Ehrnreiter from January 1, 2014, to the present.

t. Federal income tax returns of Mr. Ehrnreiter for the year 2014 to the present.

NOTICE TO JUDGMENT DEBTOR

IF YOU FAIL TO APPEAR AT THE TIME AND PLACE SPECIFIED IN THIS ORDER, YOU MAY BE SUBJECT TO ARREST AND PUNISHMENT FOR CONTEMPT OF COURT AND THE COURT MAY MAKE AN ORDER REQUIRING YOU TO PAY REASONABLE ATTORNEY'S FEES INCURRED BY THE JUDGMENT CREDITORS IN THIS PROCEEDING.